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Re: Recent FAA Sport Pilot Interpretation

Can an ATP candidate count all his time with his CFI????

Re: Recent FAA Sport Pilot Interpretation

Walter Coats
I am a private pilot, with instrument rating, a sport instructor and have logged about 500 total hours with about 300 dual given. There is no way that a sport instructor should be counted at the same level as a regular instructor.

I, too, am a private pilot, with no instrument rating, but a CFI-SP and about 200 hours in my own LSA. When I joined SAFE at Oshkosh, I was told I was one of the first, if not the first, CFI-SPs in SAFE.

To me, it comes down to a simple question: What's different about the instruction given by a CFI-SP as opposed to the instruction given by a CFI-A? The answer is that, for those things that are common to sport and private pilot ratings, not a doggone thing!.

True, I'm not qualified to teach a pilot how to do a chandelle. That's not required for the sport pilot rating. I am qualified to teach everything in the sport pilot standards, and to the same standard of performance as a private pilot doing those same maneuvers. I know darned good and well that the examiner tested me to the same standard as he would a CFI-A. We had that discussion before the checkride began. He feels, and I agree wholeheartedly, that a CFI-SP must be able to teach to the same level of performance as a CFI-A, in order for sport pilots to be as safe as their privilege set allows.

Yes, there are some incredibility talented sport instructors out there but there are also a whole lot of them who don't know an aileron from an elevator.

...just as there are CFI-As at both levels of performance you cite. The level of certificate does not tell the story. The professionalism and level of ability does.

I don't think we can make universal comments about either group of CFIs. Not all of the H CFI's are youngsters who are airline bound.

I agree. Why, then, do you make universal comments about CFI-SPs such as
There is no way that a sport instructor should be counted at the same level as a regular instructor.
...?

Sport instructors are given the respect they deserve. My background is in accounting. And yes, we have a large number of really great bookkeepers (many have college degrees in their field, even), but that does not mean they should have the same privileges as a CPA. On the other hand, there are some very poor CPAs who can't balance a checkbook.

The difference is that bookkeepers aren't tested to any level of proficiency. CFI-SPs are, and for the elements that are in common, that level of proficiency is identical to that of CFI-As. This is where your analogy falls flat.

Which side of that line a bookkeeper or a CFI is on is in no way an indication of their experience or talent. However, it is still important to have the mark in the sand and that we respect it.

We give that mark the respect it deserves when we recognize that a CFI-SP is not qualified to teach those things that are not in the sport pilot PTS. That's all that's needed. The standards are the same for CFI-SP and CFI-A for those things that are common, and that's the reason that CFI-SPs' training should count toward the private ticket. Anything less does not grant the CFI-SP the respect he deserves, and indeed does not grant the sport pilot rules the respect they deserve.

Re: Recent FAA Sport Pilot Interpretation -- I support it.

Walter hit the nail on the head. Nice job. I am glad someone had the fortitude to speak up about this.

I am tired of our professional education associations dumbing down the standards. The public school teachers union protects the bad teachers who have seniority over the good.

NAFI, SAFE, etc... are supposed to be promoting professional flight training. I know Helen will point out her exceptions to the rule, 2000 hour F16 pilot, but the vast majority of the instructors who are sport only are only Private pilots with 150+ hours. By the way, why doesn't this pilot have a full CFI rating (instrument & commercial)? He surely can pass the test. He should be leading by example for his students and continuing to improve his ratings.

Bookkeepers are not the equivalent of a CPA. 8th graders are not college graduates. Private pilots are not the equivalent of an Instrument, Commercial, traditional full CFI. They don't know...what they don't know.

How can they teach judgment and pass on skills they have not yet attained.

I urge everyone who believes in professional education to call NAFI, EAA, and the FAA and support making a flight instructor certificate mean something.

Respectfully,
Scott Johnson
Chief Pilot LSA North, Stick-n-Rudder Flight Training

Re: Recent FAA Sport Pilot Interpretation -- I support it.

Amen, Amen and Amen to Scott. I'm with you bro'.

Consider that the private pilot has the privilege of flying very fast aircraft, at very high altitudes, and in some pretty crummy weather.

Granted they may have no intions to do it, but they have the privilege if they one day int he future chose to. Therefore, they need instruction that starts from the beginning in building sound habit patterns and thought processes that matches those privileges.

In the end it comes down to servicing customers. The customer needs some method of evaluating the professional status of the instructor he chooses to hire. Say what you want about the way things SHOULD be, but that is why we have instument instructors, multi-engine instructors, Cessna CFIAs, Cirrus Instructors and Master Instructors ... we attempt to find ways for the customer to better understand the unique credentials of our professional credentials.

As far as the FAA, their purpose is to protect public trust in our system of training and issuing credentials to our instructors.

Re: Recent FAA Sport Pilot Interpretation -- I support it.

Regina Marin
Consider that the private pilot has the privilege of flying very fast aircraft, at very high altitudes, and in some pretty crummy weather.

Granted they may have no intions to do it, but they have the privilege if they one day int he future chose to. Therefore, they need instruction that starts from the beginning in building sound habit patterns and thought processes that matches those privileges.

Those sound habit patterns and thought processes apply just as much to sport pilots as they do to private pilots, and any competent CFI-SP will be training them from the beginning. Remember the principle of primacy?

There's very little different between training at the sport level and training at the private level until you get to hood time and night.

Re: Recent FAA Sport Pilot Interpretation -- I support it.

Scott Johnson
I am tired of our professional education associations dumbing down the standards.

What standards, exactly, are "dumbed down" for CFI-SP as opposed to CFI-A, and how, exactly, do they relate to training sport pilots or the elements of the private ticket that are common to sport pilot?

NAFI, SAFE, etc... are supposed to be promoting professional flight training.

Professionalism is in the mind of the instructor, nowhere else.

By the way, why doesn't this pilot have a full CFI rating (instrument & commercial)? He surely can pass the test. He should be leading by example for his students and continuing to improve his ratings.

I can't speak to Helen's example, but I don't have the commercial and instrument and CFI-A because I can't pass a medical. Does that make me less qualified as an instructor?

Bookkeepers are not the equivalent of a CPA. 8th graders are not college graduates. Private pilots are not the equivalent of an Instrument, Commercial, traditional full CFI. They don't know...what they don't know.

I'll agree with you just as soon as you can explain to me how this is relevant to training those elements that are common to the sport and private tickets.

How can they teach judgment and pass on skills they have not yet attained.

How can a 250-hour wonder teach judgment, either? As the Kings put it, good judgment comes from experience, and experience comes from bad judgment.

I urge everyone who believes in professional education to call NAFI, EAA, and the FAA and support making a flight instructor certificate mean something.

Right now, my CFI-SP doesn't mean squat, especially to those who hold attitudes like yours. Gee thanks.

Chief Pilot LSA North, Stick-n-Rudder Flight Training

I wonder what your students think of your attitude toward sport pilots.

If you'd like some time, come down to Fairmont, and I'll be happy to take you flying in my LSA with my lowly CFI-SP ticket and we'll see what you think.

Re: Recent FAA Sport Pilot Interpretation -- I support it.

Jay

I am referring to SP instructors, not ordinary Sport Pilots. I think very highly of Sport Pilots, and especially those who go on to attain higher ratings and/or continue learning.

If you will review the FAR book, and since you are an instructor, I assume that you own one and know where to look... you will see the difference in the minimum requirements of a SP instructor and a CFI.
Read the part about minimum flight time and experience requirements.

I am not bashing you, or any other SP instructor. But I think our customers deserve more than what the majority of low time SP instructors are able to provide.

Lastly, the last place I want to get in a my weener is bigger contest is in your airplane, or any airplane. Let's keep the macho discussions on the ground. Then again, you are proving my point on judgment...is this what you teach your students? Challenge them to a fly off?

Who was your examiner? I would like to talk to him or her and see what their opinion is.

Regards,
Scott

Re: Recent FAA Sport Pilot Interpretation -- I support it.

Scott Johnson
If you will review the FAR book, and since you are an instructor, I assume that you own one and know where to look... you will see the difference in the minimum requirements of a SP instructor and a CFI.
Read the part about minimum flight time and experience requirements.

Yup, I have. The difference is not as big as you think, and I met the minimum flight time and experience requirements for CFI-A when I took my CFI-SP checkride. I don't meet the minimum rating requirements, because you have to have a medical to take the checkrides for the instrument rating and the commercial ticket.

I am not bashing you, or any other SP instructor. But I think our customers deserve more than what the majority of low time SP instructors are able to provide.

That certainly sounds like bashing to me...

Lastly, the last place I want to get in a my weener is bigger contest is in your airplane, or any airplane. Let's keep the macho discussions on the ground. Then again, you are proving my point on judgment...is this what you teach your students? Challenge them to a fly off?

WHOA! That's not anything like what I'd intended to say, if indeed I did say it. I absolutely agree that an airplane is the worst possible place for a macho contest. I was trying to say that I'd be happy to let you evaluate my flying and teaching abilities and judge for yourself. I'm comfortable that I can fly and teach, but you apparently don't believe so, based on nothing more than what I've said here and on the Yahoo! Sport_Aircraft list. I don't particularly think that's fair.

Who was your examiner? I would like to talk to him or her and see what their opinion is.

If you were to post that question to the Sport_Aircraft list, he'd see it and, if he chose to, he could answer it. I'm not going to give his name here without his permission.

Re: Recent FAA Sport Pilot Interpretation

From my perspective as an examiner, what I am looking for when an applicant comes for a Private Pilot Practical test, is that the applicant has met, amongst other things, the aeronautical experience requirements for the certificate. In the transition from Sport Pilot to Private Pilot a minimum of at least 10 hours of additional instruction, given by a CFI, to a person seeking the transition would be required. (1 hr. x/c; 3 hours instrument; 3 hours night, 3 hours in preparation for the practical test).

As long as the instructor endorsing the student's logbook as well as signing the recommendation on the 8710 is a CFI, and the applicant can test to the PTS, I don't think it matters whether the hours gained in obtaining the Sport Pilot certificate came from an SPI or a CFI. The bottom line is that a CFI is the one who determines whether the applicant is capable of flying to Private standards, or not.

So I guess the short answer is I think training given by a Sport Pilot Instructor should be acceptable in meeting the requirements of a Private Pilot Certificate.

Re: Recent FAA Sport Pilot Interpretation

The examiners where I come from look at the 8710 as the primary data source for the Private Pilot candidate. They don't care whether cross country time was earned overseas, in what kind of airplane as long as it was single engine land, or, frankly, who the primary instructor was. The 8710 must be endorsed by a quilified and current CFI, that's all.

Re: Recent FAA Sport Pilot Interpretation

Doug makes a good point about it being the responsibility of the CFI endorsing the private pilot for a practical exam.

However - consider this - might that sport instructor conduct a cross country that is at least 50NMs long (then the candidate does not need another x/c to meet the requirements of a private) and might that sport instructor conduct 3 hrs of hood time (then the candidate does not need additional hood) and if that sport instructor is a private pilot, then he may instruct after dark (thus, the candidate does not need additional hours for night.)

So, it could be that the sport pilot feels that he is eligible (maybe not proficient, but eligible) for a private pilot certificate after receiving/logging 3 hrs of prep in the preceding 60 days.

That's the focus we have to stay on - the guy writing the checks - and is he really getting his money's worth by thinking that instruction from a SFI is the same?

I'm jus' say'in ... think about it! That woman might have the big sport school and if she's the manager then I'm sure they do a good job - but there are a lot of individual SFIs working without supervision who are in no way prepared to give this training of the calibre that a private pilot needs.

Thank you SAFE for allowing me to express my opinion. I mean no disrespect to my fellow K CFIs, I just think we work in two different aspects of aviation.

Re: Recent FAA Sport Pilot Interpretation

Having addressed the CFI's responsibility in providing the proper logbook endorsements and 8710 recommendation, let us not forget the DPE's responsibilities in ensuring that the applicant has met all the requirements for the certificate applied for.

As an example, an applicant for an instrument rating must have received a minimum of 15 hours of dual instrument instruction from an "authorized" instructor. A DPE who is really doing doing their job will now have to check to be sure that those 15 hours were provided by a CFII, and do not include the 3 hours the applicant might have received during training for the Private Pilot Certificate, - IF - those three hours were provided by a CFI.

So you see, as an examiner, I will have to check, not only the total aeronautical experience to ensure that it meets the minimum requirements, but further what type of instructor certificates and/or ratings were held by the instructor providing that training for those areas of the experience requirements that necessitate a CFI. It becomes my responsibility, as an examiner, to ensure that those areas of instruction were provided by an "authorized" instructor.

So I don't personally see a problem with an SFI providing instruction for those Tasks and Objectives that are common between the two certificates, so long as a CFI provides the logbook endorsements, and 8710 recommendations as well as the training that is not common for the two different certificates.

FAA Sport Pilot Interpretation - Question

Hello Doug --

It is first the student's obligation to make sure the 8710 reflects all the aeronautical experience required. Second, it is the recommending instructor's obligation to see that the 8710 reflects all the aeronautical experience required. Then, third, as you point out, it is the DPE's obligation to see that the 8710 reflects all the aeronautical experience required.

Does the FAA, through IACRA, or otherwise, give you access to the ratings associated with a particular flight instructor certificate number? My certificate is simply 9999999CFI expiring 9/11. How is the reader of a logbook to determine the qualifications of the instructor signing each line?

I suppose, but I don't know for sure, that IACRA will only allow an instructor with Instrument Airplane priveleges to recommend a candidate for the Instrument Airplane rating. But for lines in the logbook, who is to know?

In what form is the certificate number for a sport pilot instructor? How do I identify the training I see in a student's logbook as sport training?

Robert

Re: Recent FAA Sport Pilot Interpretation

In answer to Doug's question to verify experience requirements were met, I use an audit worksheet during review of a student's log. This is the only sure way to determine all experience requirements are met. I'll also have the student complete one and keep it for the practical test. It gets him more familiar with his log book and... If the DPE needs to see what lessons culminate to meet a particular requirement, the student is more easily able to turn to those dates listed and show the times logged.

Re: Recent FAA Sport Pilot Interpretation

When the FAA passed this rule, I don't believe that it was ever the intention to dumb down the private instruction given or to inflate the sport instructor status.

As I recall, the discussion about sport pilot began during 9/11 and the fact that we had all those ultralight pilots who were not certificated flying in aircraft that were not certificated. They also had ultralight instructors teaching these pilots who were not certificated, but who were on a list by an organization.

The FAA had no way of knowing who was flying in our skies. It was a national security issue - that's why we have consensus standards - because this all started in the Justice Department. The sport pilot was a means to get those pilots and instructors certificated so that they were on public record.

Did you ever wonder why these rules passed so fast? National security more so than wanting to save or promote general aviation.

Now suddenly there are folks who want to say that a sport pilot is the equivalent to a mini private and a sport instructor is as good as a regular instructor. I hate to burst your bubble, but in case you don't know it, there are several sport instructors out there who were "grandfathered" meaning that they took NO FAA practical exam. The FAA had to start somewhere and that's how they did it.

Read over Paul Hamilton's Sport Pilot Guide to the Oral or better still, watch his first flight video. This is a guy who pumping information out to others as a sport instructor and examiner. Any instructor who has given 10 hours of dual can find 100 (that's no exageration, I started a list and counted them) mistakes and points of poor performance/technique in that video.

This is one example of what I am talking about. Any pilot coming from that background will require 20 hours of instruction from a regular instructor just to correct all the bad habits taught by that sport instructor. That other respondent who referred to our paying customers got it right. Our students deserve better.

Re: Recent FAA Sport Pilot Interpretation

Marshall Quinna
This is one example of what I am talking about. Any pilot coming from that background will require 20 hours of instruction from a regular instructor just to correct all the bad habits taught by that sport instructor. That other respondent who referred to our paying customers got it right. Our students deserve better.

I agree our students deserve better. Who says that a CFI-SP can't deliver that? Not all of us are grandfathered from the ultralight world. I took a checkride with a regular designated examiner, and I'll stack my test up against anyone's, CFI-SP or CFI-A.

There are lousy instructors at all levels of certification. You have to look past the ticket.

Re: Recent FAA Sport Pilot Interpretation

“Let he who hath not sinned throw the first stone.”

For every subpart K instructor real or imagined mentioned in this discussion who doesn’t “know an aileron from an elevator” I can name a subpart H instructor of equal caliber who actually interviewed with me for a job. The most recent one, an ERU grad, had worked at two flight schools, including a 141 academy before taking several charter gigs and eventually finding his way to my doorstep. He was not an AOPA member, had never heard of NAFI, could not tell me what EAA stood for, and best of all, had held all of the aforementioned jobs while operating on an invalid pilot certificate as he had never changed his address with the FAA. When he asked me why this mattered, and explained it mattered primarily for the sake of insurance to which he exclaimed, “Oh that’s not a problem since I don’t have any insurance!”

There will always be both good and bad instructors on both sides of the alphabet. How does the FAA deal with this and ensure that we only graduate students of appropriate skill and knowledge levels? Through the PTS and a controlled system of examination. If a student is examined by an FAA DPE and can meet the test standards set forth, how can we say that his training was inadequate because of the pedigree of his first instructor?

Helen

Re: Recent FAA Sport Pilot Interpretation

To the "real" CFI's out there, let's end this discussion thread. There's no use in trying to communicate with this SFI group.

Just by the debate that is blooming here, one can see their "poor me, life is so unfair" mindset. It's obvious to me that they will be passing this along to their students and anyone else who will sympathize with them. Get over it. Life IS unfair. And the weather forecasts are wrong 50% of the time and ATC doesn't always give the clearance I need. Deal with it.

I don't know if the rest of the SFI industry is represented by those posting on this forum, but I sure hope not.

Previous to reading these posts, I would have said that we are all equal as professional instructors - however, after reading here, I can see that there is a big difference between these SFIs and CFIs. I am shaking my head with dissappointment.

I'm not talking about hours, or experience, or teaching methods or credentials - it's a simple mindset that one earns with additional training. It's a businesslike attitude regarding the privilege of flying and it appears to be lacking here in the postings from SFIs.

If I was on your side before - I am no longer. I hope the FAA does not change the interepretation.

Re: Recent FAA Sport Pilot Interpretation

Well said! I urge you to email NAFI, SAFE, EAA, AOPA, and the FAA with your thoughts. I have. They need to hear from the rest of us "clear thinkers" as well.
Scott

Re: Recent FAA Sport Pilot Interpretation

After reading through this thread it seems to me this goes back to the age old debate - sailboats or powerboats - Fords or Chevys.

Primary training is just that - primary training. The canidate will have to pass a PTS. The people that will suffer the outcome of this are the students. The ones that have and are now being trained by the CFI-SP. To my knowledge, all those Sport CFI's out there had to take and pass a PTS for Sport CFI.

At Sun N Fun I stopped in the SAFE booth to check out what they are about. My checkbook ready, I was pitched why I should join. I was told they didn't have any Sport Pilot instructors join yet. I put my checkbook away and decided I would reserve judgement and joining for a later date. I felt a definite air of elitism. I have always supported those that support me. Don't feel any support here. This group (SAFE) may be suitable for 'real' CFI's and other 'gods of flight'.

Re: Recent FAA Sport Pilot Interpretation

Robert Snyder
To my knowledge, all those Sport CFI's out there had to take and pass a PTS for Sport CFI.

I certainly did, and from my discussions with the CFIs around my home field and from the conversations I had with my examiner, I'm totally convinced that I was held to the same standard as an applicant for CFI-A.

At Sun N Fun I stopped in the SAFE booth to check out what they are about. My checkbook ready, I was pitched why I should join. I was told they didn't have any Sport Pilot instructors join yet. I put my checkbook away and decided I would reserve judgement and joining for a later date. I felt a definite air of elitism. I have always supported those that support me. Don't feel any support here. This group (SAFE) may be suitable for 'real' CFI's and other 'gods of flight'.

I certainly didn't get that vibe from the folks I talked to at Oshkosh. In addition to a couple of SAFE officers, I spent quite a bit of time talking with the Hills about the events leading up to the formation of SAFE. I'm a Professional Registered Parliamentarian, and the issues involved were ones I'd dealt with many times before. Not once during that whole series of conversations did I feel like I was thought of any less as a freshly minted CFI-SP than if I had been an experienced Master CFI.

I believe the naysayers here do not represent the thinking of the officers and board of SAFE. I think it's incumbent on SAFE to represent the interests of the entire aviation education community, of whatever rating - or none at all. From what I heard at Oshkosh, that's what SAFE thinks, too.

Re: Recent FAA Sport Pilot Interpretation

Sam Cleno
To the "real" CFI's out there, let's end this discussion thread. There's no use in trying to communicate with this SFI group.

"We must all hang together, or we shall most assuredly hang separately." Those words of wisdom apply in today's aviation world just as much as they did in 1776.

Just by the debate that is blooming here, one can see their "poor me, life is so unfair" mindset. It's obvious to me that they will be passing this along to their students and anyone else who will sympathize with them.

Uhm. Huh? I have no idea where you got this from. My focus as an instructor is on providing the best training I possibly can in order to give my students the tools they need to become safe pilots. What's yours?

I don't know if the rest of the SFI industry is represented by those posting on this forum, but I sure hope not.

Wow. All I can say is wow.

I'm not talking about hours, or experience, or teaching methods or credentials - it's a simple mindset that one earns with additional training. It's a businesslike attitude regarding the privilege of flying and it appears to be lacking here in the postings from SFIs.

You don't have to make a living from something to be a professional, and you don't have to have a commercial ticket and an instrument rating to be a good teacher. Plenty of top-notch pilots out there are terrible teachers. It's about teaching, and that does not correlate directly with anything.

If I was on your side before - I am no longer. I hope the FAA does not change the interepretation.

I wish I knew what it was that changed your mind, because nothing I saw in this discussion would lead me to the same place you've gone.

Re: Recent FAA Sport Pilot Interpretation

I will admit that I am not an instructor of any kind and that I found this website by accident during a routine google search. I took sport pilot training at Aero-Tech where Arlynn McMahon is chief instructor ans so I was curious to read the postings here. As there has been mention of customers and students, I thought I would drop a few thoughts from that perspective.

I am 68 years old. In January of this year, after about 3 weeks and 24 total hours, I joined the ranks of pilot-hood. In February I purchased a brand-new LSA and in July I flew to OSH (my longest x/c to date) to watch Arlynn receive her award. In October I hope to fly to the Grand Canyon with my grandson.

I have also continued with my training with WINGS, spin training, high altitude physiology and survival training. (Aero-Tech plans training opportunities.)

I now have 140 hours and have begun to entertain the possibility of adding a private pilot and a sport instructor certificate as a way to continue flying on a retirement income. I think adding a private pilot is important for my confidence and for my future students. I want to be the best I can be.

Thru my training activities I have flown with 6 different instructors - I liked getting different perspectives, they each bought me something new in addition to flight skills. I never knew exactly what credentials any of them had, I assumed that the school hired good talent. It never occured to me to ask, "Are you a sport instructor or a regular instructor." I didn't know there were different instructor credentials. I accepted them all on the basis of how well I liked and learned from them.

Each instructor seemed to have his "specialty." One was a LSA specialist, one was a TAA specialist, one was especially talented in scenario-based training. One was a weather specialist. This "specializing" seemed to work very well for students in training and the instructors liked it as they were not forced to become specialists in all areas of a broad general aviation set of skills.

As I look forward to the possibility of adding a private pilot, I will look for that portion of aviation that I MOST enjoy and (even though I must be good at everything) I will strive to become a specialist in one aspect of aviation.

I don't see doctors arguing that the brain specialist is any better than the foot specialist. I see that Doug (the president of SAFE) specializes in training in the NY corridor. I might pop up for some instrction from you, Doug. I think it's good to learn from each other. As Arlynn says, "He who dares to teach, must never cease to learn." I am glad I found Aero-Tech before I found this debate. It would have confused me beyond hope.

A paying customer and a student.

Re: Recent FAA Sport Pilot Interpretation

Joe (et al),

VERY well said, Joe, and hopefully read by all. I (WE) are glad you found the site, and thank you for your very well stated thoughts and information about your training and goals. We are all very proud of Arlynn, and you got your start in a great place. Keep going with your training and welcome to Aviation!

As you can tell, we are passionate about what we do, and it sounds like you are as well - but your comments are also well reasoned and sound. Thanks for helping to bring this back down to a well grounded discussion.

Best Regards - and have a SAFE day!

Alan

Re: Recent FAA Sport Pilot Interpretation

On July 24th, 2009, the FAA Office of the Chief Counsel issued a letter of interpretation stating that the flight training provided by subpart K instructors (those with only a sport pilot instructor certificate) cannot apply toward the flight training time required for the private pilot certificate (normally, this training is provided by a subpart H certified flight instructor).

From the four-page letter of interpretation written by FAA attorney Paul Greer, the FAA’s rationale for this ruling can be distilled down to a single argument supporting the agency’s position:

“Permitting a sport pilot to use flight training provided by a flight instructor with a sport pilot rating…to meet the aeronautical experience requirements for the issuance of a private pilot certificate however, would be the functional equivalent of permitting that instructor to provide flight training for the issuance of a private pilot certificate…. It [the FAA] did not intend to decrease the minimum experience requirements for flight instructors who provide training for the issuance of private pilot certificates….”

My position relates only to flight training in the light sport airplane category, although I believe the following argument holds true for other categories and classes of aircraft. In my opinion, the flight training provided by sport pilot instructors is sufficiently similar in both the quality and quantity (with the exceptions listed below) to that provided by certified flight instructors that some or all of this flight training time should be applicable toward meeting the private pilot flight training requirements. My reasoning follows.

It’s true that sport pilot instructors are not required to provide training in basic instrument maneuvers, night flying and electronic navigation to the sport pilot, nor are these instructors required to possess this knowledge themselves. Knowledge in these three areas, however, represents only about 15% of the total flight training knowledge required by a private pilot applicant. This means that 85% of the flight training provided by a sport pilot instructor to sport pilot applicants is identical to that provided by certified flight instructors to private pilot applicants. In fact, Paul Greer writes, “The FAA recognizes that many of the areas of operation on which an applicant for a sport pilot certificate is required to receive training are identical to those on which an applicant for a private pilot certificate is also required to receive training….” The areas in which the received training is identical is based on an examination of the FAA’s own Practical Test Standards. (The PTS identifies the minimum standards of competency that the FAA requires of all pilot applicants.)

Comparing the sport and private pilot Practical Test Standards reveals that every single flight maneuver required of a sport pilot applicant (less basic instrument maneuvering and electronic navigation) is also required of the private pilot applicant. The Practical Test Standards also make it clear that the areas of operation, tasks, objectives and minimum proficiency levels for both sport and private pilot applicants are fundamentally the same, with no practical difference between the two. It’s clear from the Practical Test Standards that the FAA requires sport pilots to demonstrate levels of performance similar to that of a private pilot applicant on the practical flight test.

It thus becomes difficult to argue that sport pilot instructors, despite having less experience, can’t or don’t provide training comparable to that provided by certified flight instructors. While it’s true that a sport pilot instructor may have less experience than his or her certified flight instructor counterpart, the FAA’s Practical Test Standards also makes it clear that this produces no practical difference in the quality of flight training provided by either instructor.

Please keep in mind here that the training a sport pilot receives isn’t somehow deficient when compared to a private pilot’s flight training. Instead, the sport pilot’s training is simply appropriate to the limitations of the airplane and regulated limits under which he or she flies (i.e., two-place, day only, at/below 10,000 feet MSL, etc.). Clearly the PTS’s completion standards indicate that in those areas where the sport and private pilot applicants receive training by their appropriately rated instructors, there is no difference in either applicant’s proficiency, skills, or competence.

Let’s also remember that sport pilots wishing to apply their flight training time toward the flight training time required for the private pilot certificate will not be deficient in knowledge or flight proficiency when becoming private pilots. The regulations require that all private pilot applicants receive a certain minimum amount of ground and flight training in very specific skill areas. Where the sport pilot regulations don’t require this training, the private pilot applicant would be required to receive that training from a certified flight instructor. In other words, the regulations ensure that sport pilots seeking a private pilot certificate will meet the minimum standards required for that rating by the FAA.

On the other hand, to be intellectually honest in this endeavor, it is important to acknowledge the FAA’s position on not lowering the experience level of flight instructors who provide training for the private pilot certificate. An instructor’s experience must, after all, count for something. It’s reasonable to assume that an instructor with more experience may have more to offer in terms of the intangibles of piloting, such as judgment and wisdom. The problem here is that these intangibles are difficult to qualify, much less quantify.

Given that sport pilots trained only by sport pilot instructors will have to spend some amount of training time with a CFI in preparation for their private pilot certificate, it’s reasonable to assume that some of these intangibles will be conveyed to this applicant. If, however, these “intangibles were not passed along to the sport pilot by sport pilot instructors, I doubt this ultimately matters in terms of safety. Why? Because there is a significant safety benefit derived from allowing sport pilots to apply their flight training time to meet the private pilot flight training requirement. This benefit consists of the economic incentive a qualified sport pilot now has to continue his or her training toward a private pilot certificate without having to worry about funding an additional 20 hours of dual instruction.

The FAA has many precedents for safely lowering the overall flight experience requirements as an incentive to attract more people to aviation (think about the reduced experience requirements for the recreational pilot certificate, sport pilot certificate, reduction in total time for instrument rating, etc.). Common sense suggests that incentives for pilots to attain a higher rating must have some positive effect on that student’s overall safety.

While I have the greatest respect for the work the FAA does, especially in the sport pilot area, I do believe that this ruling undervalued the capabilities of sport pilot instructors. I also believe that the FAA didn’t properly weigh the safety benefits of encouraging students to continue training as compared to the loss of those intangibles associated with an instructor’s lesser experience.

I hope that the FAA will reconsider allowing some or all of the flight training time provided by sport pilot instructors to sport pilots to apply toward the private pilot flight time requirement.

Sincerely,

Rod Machado
August 20, 2009

Re: Recent FAA Sport Pilot Interpretation

Bravo, Rod! I hope the naysayers here take your words to heart.

Please tell me you sent this to the FAA in one form or another...

Re: Recent FAA Sport Pilot Interpretation

Rod

ON the money! As I state in my August 21st posting: "...So we should *unanimously* support sport pilot instruction conducted IAW the FARs as legal, valid, and acceptable training towards additional certification requirements."

Sincerely, Tim Collins

Re: Recent FAA Sport Pilot Interpretation

Why don't we all just unanimously support all CFI getting additional training (an instrument rating and commercial ticket) and raising the bar and not lowering it?
I still say 8th graders are not qualified to teach college classes.
Rod’s argument makes no sense. Unless, perhaps, he has a new comic book out for Sport Pilots and he does not want to upset his readers. Food for thought.

Re: Recent FAA Sport Pilot Interpretation

Not all of us are eligible to take instrument and commercial checkrides. That doesn't mean we can't teach.

Re: Recent FAA Sport Pilot Interpretation

Oh, by the way, Scott, you still have not explained exactly what makes the training for those items common to sport and private pilots different between the two to the point that a sport pilot CFI's instruction on those items is not sufficient.

In the absence of such an explanation, it is you who comes off sounding like he's trying to protect his business, as opposed to Rod's detailed and exhaustive analysis.

Rod's also a well-known, recognized expert in flight training.

I suspect his opinion will sway more folks than yours will, especially if you continue to resort to simplistic sound bites without the same level of detailed analysis to back them up.

Re: Recent FAA Sport Pilot Interpretation

Jay
I have written extensively on this topic on this, and several other, forums and letters to the FAA, EAA, AOPA, and NAFI. My position and that of many other respected instructors that agree with me, that we need a higher standard, has been well documented.
I am told by these authorities, that more people are writing to them that supports my position than against. It is only here, on the forums, that a vocal minority is being pro-Sport Instructor being equivalent to a traditional CFI.
The main item is the learning curve a pilot goes through when he goes from Private, to Instrument, to Commercial to CFI. A pilot who goes from Private to “Instructor” is missing out on a ton of personal achievement, experience, and flight training that needs to be passed on to a student. The judgment and ADM abilities one gains in that time period is (for most people) immense.
I was at an FAA Safety meeting tonight (CFI and DPE), and the speaker said “You don’t know…what you don’t know. You need someone who knows, to teach you.”

Sound bites work best...for those who don't know, or don't want to know, all the facts.

Scott

Re: Recent FAA Sport Pilot Interpretation

I don’t think the Sport Pilot Instructor being ‘equivalent’ to a CFI is at issue. I thought we were all talking about credit for instruction for a sport pilot ‘upgrading’ to private pilot? I recently talked with a sport pilot who has logged over 275 hours flying time in just two years. He now is considering a Private ticket. Is it fair to him to repeat basic flying skills because his training didn’t count towards a private license or would it be reasonable to assess his skill to date and proceed with night, radio nav and hood training (or any other skills and requirements to pass the Private PTS)?
One note about the difference in training…a private pilot does not have to train in B, C or D airspace but yet is legal to enter such airspace, whereas a sport pilot must receive additional training and endorsement to be legal. Food for thought.
It comes down to the student. We have all seen instructors that can’t teach… some are here only as time builders. Unfortunate, but true. The Sport CFI’s I’ve encountered are here for the student, not the career path to the airlines. These Sport instructors offer quality instruction and pass their passion for flight to the student. I’m sure we can find examples of good and bad instructors at either level. Students will quickly discover which are good and the bad. I don’t think all Sport Pilot instructors are low time with little experience.

Re: Recent FAA Sport Pilot Interpretation

Rod said it best of all things written here.

There is this huge concern time and expense is lost when going from Sport to Private Pilot. As said, little is lost. Even so, I've yet to see someone moving forward who did not need a bit of recurrent training to bring back some lost skills.

SP instructors have a definite place. Are there some who don't quite have the experience level maybe they should have? Heck, that can be said of CFI-A or even the new 738 type rating when all they had flown before was a C441. There will always be a need to increase experience and improve skill. I'm sure the best among us such as Rod, Doug and Arlynn will feel the same. We never stop learning and neither do they.

For anyone to dump on another because their experience level is less only diminishes their value as a teacher and inflates apparent ego that gets in the way of being a good teacher. I tell my students to never be afraid to question me. I'm not infallible. Them seeing me correct my my mistakes will reinforce the need to also stay on top and verify their own actions. It's all part of ADM, something I very little of out of many instructors.

If someone comes to me inquiring of SP, I'll ask of their goal. If it's cost and a way to get started, I'm fine with that. If it's a means of cutting corners because they "don't have to do as much" then I'll be very concerned about their motivation as applied to safety. But, if I see any consideration of moving toward private pilot right away, I'll suggest doing so from the start.

I don't really agree with the FAA decision but I understand the logic applied. Either way, that's the rule. Now, we need to live within that rule and help each other out.

By the way, how many instructors seek training beyond what it took to achieve their current level of certificates? Is there a plan to improve their skill beyond what it is now? I plan to move toward aerobatics to make me more proficient in overall aircraft handling in upset attitudes. Just because one holds only a SP instructor certificate, they are not forbidden to acquire instrument skills. They can't teach them but it will certainly improve overall skills and add to their experience level. The CFI-A out there... what more have you done to improve your skill and experience level?

I don't think anyone on this forum has so much they can point fingers. Anyone who does would be due to retire from teaching.

Pardon my rambling,

Ken

Good Day!

Re: Recent FAA Sport Pilot Interpretation

I fully support the FAA revising the regulation. The SP CFI should be fully certified to provide PP credit for any pilot wishing to upgrade.